Air permit applications

NSR/NNSR/PSD/GHG/TITLE V/PBR

The air permitting process has become significantly more complex over the past 20 years. ACS Engineering has been there every step of the way.

There are numerous forms, checklists and guidance documents to walk applicants through the process of air permitting. However, unless your proposed operation is highly simplistic, the likelihood of securing the best outcome for your operations is low without the air compliance management expertise of ACS Engineering.

What is Nonattainment vs. Attainment?

Nonattainment areas are defined regions within the state that have been designated by the United States Environmental Protection Agency (EPA) as failing to meet the national ambient air quality standard (NAAQS) for a pollutant for which a standard exists. Major NSR permitting is done on a pollutant-by-pollutant basis. A project may be considered a major modification for one pollutant and Best Available Control Technology (BACT) or Lowest Achievable Emission Rate (LAER) would only be evaluated for that pollutant.

How long does it take to receive a GHG permit?

State and local permitting authorities have been delegated the authority to issue Clean Air Act permits to sources of GHG emissions. Authorization for GHG emissions will therefore be granted within the same time frame that the state or local permitting authority has established for their Clean Air Act permitting program. Sources should generally not expect the issuance to be any sooner than six months from the date the administratively complete permit application has been submitted and twelve months is a more common timeframe.

What is an emission offset?

Offsets are emission reductions which were generated by reducing or eliminating emissions beyond a regulatory requirement. Proposed projects may be required to offset the emissions increase from the new source or modification and provide a net air quality benefit by securing available offsets from other sources. Emissions offsets allow an area to move towards attainment of the NAAQS while still allowing some industrial growth.

A well-planned air permit strategy and the expertise to move your application through submittal to issuance can be as critical to your success and bottom line as proper engineering work to design your operations. The air permit you are issued will specify the construction that is authorized, the air emission limits that must be met and the production capacity of your operations.

The Hazards of Air Permit Missteps and Noncompliance

Failures and missteps in the air permit process are costly because they typically hinder your operations and flexibility by saddling you with bottlenecks. Potentially applicable environmental regulations are numerous and complex. In addition to indicating which regulations are applicable, the specific requirements of applicable rules must be identified and implemented.

Failure to comply with any applicable requirement will result in violations and penalties, and failure to properly claim non-applicability from rules will result in additional environmental compliance costs that should not be a part of your compliance budget.

Navigating the Complexities of NAAQS

National Ambient Air Quality Standards (NAAQS) have become more stringent and air dispersion models have become more conservative. This has made compliance demonstrations one of the most time-consuming aspects of the air permit application process. Securing a permit once the application has been properly prepared and submitted may not be a certainty, even after satisfying all applicable regulatory requirements. Air permit applications and amendments generally leave you at the mercy of the permit writer and the public, who can demand further concessions prior to issuance of the permit.

Understanding what is and is not reasonable along with an understanding of how those negotiated terms are going to impact your operations and bottom line are critical compliance management skills ACS Engineering brings to the table.

Our Proven Air Permit Strategies Drive Permit Success

ACS Engineering achieves permit success for you through implementation of proven air permit strategies. We have the industry and regulatory expertise to understand all of the variables that will impact you and capture all of those variables in detailed models. With our models complete, you and ACS Engineering can fully understand the impact that each emission point parameter has on your ability to operate—and the permit actions that will result from any changes to the variables. We know how to work with regulatory and environmental agencies to avoid pitfalls that can cause your permit application to fall into a black hole.

ACS Engineering has completed thousands of New Source Review (NSR) permits including Nonattainment New Source Review (NNSR) and Prevention of Significant Deterioration (PSD) permits, Acid Rain permits, Title V permits and Greenhouse Gas (GHG) permits. Many of these environmental management projects have involved cleaning up air permit problems caused by entities that didn’t have ACS Engineering’s superior understanding of the air permitting process.

Your air permit is too important to take chances on. Go with the proven team of environmental consultants at ACS Engineering.